CLE Course Details

International Taxation: Introduction to U.S. Transfer Pricing, Part II

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Price: $55
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  • Description

    The statutory and regulatory history of US price controlled transactions between controlled taxpayers involving intangible property is a fascinating field of study. This CLE course will explore this issue as well as the new provisions signed into law by the Tax Cuts & Jobs Act. The course will explain the concepts surrounding intangible property that inform the US transfer pricing between the IRS and taxpayers and the IRS and outside government with whom we maintain tax treaties including commensurate with income principles, aggregation, cost sharing, Pillar 1 and Pillar 2 of the OECD’s proposals and realistic alternatives.

  • Instructor Bio

    William Lundeen

    Bill Lundeen has served in tax positions in all three branches of the federal government: on Capitol Hill, at the United States Tax Court, and at the Internal Revenue Service as a Senior Counsel Attorney and Tax Law Specialist. At the IRS Bill negotiated multi-lateral APAs concerning global trading of derivatives and he and his teams resolved double tax disputes with other governments. For four years Bill was appointed as the General Counsel of the State of Illinois Department of Revenue with ultimate responsibility for all Illinois tax law positions taken during that time.

    In the private sector Bill began his legal career in New York City with the renowned boutique tax law firm of Everett, Johnson and Breckinridge, a member of the Miller & Chevalier network of tax law firms. Bill also provided multi-state and international tax controversy services to clients as a partner in two public accounting firms most recently Ernst & Young LLP. At EY he served as Partner and Midwest Practice Leader of the Tax Controversy and Risk Management Services team which represented clients before the Internal Revenue Service Large Business & International Operating Division and before the IRS Office of Appeals. In addition to ultimate responsibility for all Illinois tax litigation between 1995-1999, Bill had specific responsibility for the federal government’s win in Intergraph Corporation v Commissioner a case of first impression under section 988, and Bill has advised the IRS on issues docketed with the U. S. Tax Court.

    Bill is a graduate of the University of Arizona where he was a member of the accounting honor organization, Beta Alpha Psi. He received his Juris Doctor from the University of Virginia where he served as an Articles Editor of the Virginia Tax Review and he received his LL.M. in Taxation from New York University.